CTF Written Submission

RE: Statement of Professor J.W. Verret at the SEC Crypto Roundtable on Privacy and Surveillance

Dec. 2, 2025
  • The SEC must clearly define the boundary beyond which government financial surveillance is illegitimate before endorsing any compliance architecture in decentralized systems.
  • Broker-dealers should be permitted—and even encouraged—to offer privacy-enhancing tools (e.g., RAILGUN, privacy pools, Zcash shielded transactions) as part of their fiduciary duty to protect clients, especially in post-withdrawal digital asset activity.
  • The SEC should not adopt international guidelines like the FATF Travel Rule without formal rulemaking under the Administrative Procedures Act, especially while related constitutional challenges are pending.
     

Last Reviewed or Updated: Dec. 2, 2025